Augst 21, 2026
DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Response to Arguments
Applicant's arguments filed 08/10/2026 have been fully considered but they are not persuasive.
Terminal Disclaimer
The terminal disclaimer filed on 08/10/2026 disclaiming the terminal portion of any patent granted on this application which would extend beyond the expiration date of U.S. Patent No. 12,075,922 B2 has been reviewed and is accepted. The terminal disclaimer has been recorded.
Claim Rejections - 35 USC § 102
The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention.
Claims 18-19 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Conner et al. (U.S. Patent No. 6,042,187).
As for Claim 18, Conner et al. teach decorative feature for use with a chair comprising: an interchangeable panel having a surface finish feature, the interchangeable panel configured for tool-less attachment to the chair; and a snap-fit feature coupling the interchangeable panel to a surface of the chair. (see column 8, lines 32-45 where it reads “Outer shell 34 is further secured to inner shell 32 via fastening tabs 116, 118, and 120. Depending upon what height outer shell 34 is being attached to inner shell 32 at, one set of fastening tabs 116, 118, and 120 are inserted into attachment apertures 146 and inner shell 32 (FIGS. 4, 5). If inner shell 32 is molded at its shortest height, fastening tabs 116a, b are inserted into attachment apertures 146 in inner shell 32. The fastening tabs are flexible and include a ridge 147 (FIG. 15) which snaps onto a retaining bar 148 in attachment apertures 146. The remaining fastening tabs 118 and 120 fit into compartments 150 and 152 defined by the grid-work formed by ribs 90 (FIG. 5). The fastening tabs in compartments 150 and 152 do not snap onto any portion of inner shell 32.”).
As for Claim 19, Conner et al. teach a surface finish feature provided on the panel, the surface finish feature including a visual indicia and a surface finish (see the specification at column 6, lines 3-11 where it reads “In order to facilitate the manufacturer of chair backs with different configurations of ornamentation, a unique identifier or indicia is molded into inner shell 32 on its back side 38 adjacent each hole 80 (e.g. 41L, 63L; FIG. 5). Different models of chair back ornamentation configurations can be defined by the specific holes 80 through which the ornamentation is secured. The unique identifiers thus allow for easy manufacture of a variety of different ornamentation configurations.”).
Claim 18 is rejected under 35 U.S.C. 102(a)(1) as being anticipated by IACOVONI et al. (U.S. Patent Application Publication No. 2011/0272986).
IACOVONI et al. teach a decorative feature for use with a chair comprising: an interchangeable panel having a surface finish feature, the interchangeable panel configured for tool-less attachment to the chair; and a snap-fit feature coupling the interchangeable panel to a surface of the chair (see paragraph [0047] where it reads “with the insert member and backrest then being removed and/or replaced with another or the same insert member and/or backrest member.” and paragraph [0049] where it reads “In another embodiment, shown in FIGS. 1-3, the backrest member includes a shell 170 coupled to front and rear inserts 172, 174. A layer of foam 176 covers the front, with fabric 178, 180 then covering the foam and the rear insert. A peripheral edge 182 of the shell remains exposed. The inserts each include a plurality of resilient tab members 184, 186, or catch members, that extend through openings 188 formed in the shell 170. The resilient tab members (catch members) 184, 186 are engaged with a snap fit to complete the assembly, sandwiching the shell 170 between the inserts.”)
Claim Rejections - 35 USC § 103
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
Claims 1, 3-6 and 11-14 are rejected under 35 U.S.C. 103 as being unpatentable over Conner et al. (U.S. Patent No. 6,042,187).
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As for Claims 1 and 11, Conner et al. teach a decorative feature for use with a chair comprising: a back support 30 (Fig. 1), and a decorative feature including a panel 32,34 to be coupled to the back support by way of a snap-fit joint 116, 118, 120, 146, the snap-fit joint having a feature configured to aid in readily engaging and disengaging the snap-fit joint, the method comprising: removing a first panel from the back support by unsnapping the snap-fit joint coupling the first panel to the back support; with the unsnapping the snap-fit joint including the user readily separating the first panel from the back support; and
and replacing the first panel with a second panel by snapping the second panel to the back support using the snap-fit joint (see the specification at column 6, lines 3-11 where it reads “In order to facilitate the manufacturer of chair backs with different configurations of ornamentation, a unique identifier or indicia is molded into inner shell 32 on its back side 38 adjacent each hole 80 (e.g. 41L, 63L; FIG. 5). Different models of chair back ornamentation configurations can be defined by the specific holes 80 through which the ornamentation is secured. The unique identifiers thus allow for easy manufacture of a variety of different ornamentation configurations.”). It would have been obvious to one of ordinary skill in the art to perform the method steps as recited in Claims 1-4 as this would be the normal and logical manner of changing a decorative feature for use with a chair as taught by the reference discussed above.
As for Claim 5, Conner et al. teach that the panel 32 or 34is formed from a plastic resin (see the specification at column 4, lines 14-16 where it reads “Inner shell 32 is depicted in full in FIGS. 3-5, and in various sections in FIGS. 6-10. Inner shell 32 of chair back 30 is molded from plastic in the preferred embodiment” and column.” And column 4, lines 64-65, where it reads “Outer shell 34 may be made of either plastic or plywood.”).
As for Claim 6, Conner et al. teach that a portion of the snap-fit 116, 118, 120, 146 feature is integral with the panel 32 or 34.
Claims 1, 3-7, 9-11, and 13-15 are rejected under 35 U.S.C. 103 as being unpatentable over IACOVONI et al. (U.S. Patent Application Publication No. 2011/0272986 A1).
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As for Claims 1 and 11, IACOVONI et al. teach the structure substantially as claimed
comprising: a back support, and a decorative feature including a panel to be coupled to the back support by way of a snap- fit joint, the snap-fit joint having a feature configured to aid in readily engaging and disengaging the snap-fit joint, the method comprising: removing a first panel from the back support by unsnapping the snap-fit joint coupling the first panel to the back support; and support, with the unsnapping the snap-fit joint including the user readily separating the first panel from the back support; and replacing the first panel with a second panel by snapping the second panel to the back support using the snap-fit joint.
including a decorative feature for use with a chair comprising: a panel 174; a snap-fit feature 186 coupling the panel to a surface of a chair; with the unsnapping the snap-fit joint including the user readily separating the first panel from the back support (see paragraph [0049] where it reads “In another embodiment, shown in FIGS. 1-3, the backrest member includes a shell 170 coupled to front and rear inserts 172, 174. A layer of foam 176 covers the front, with fabric 178, 180 then covering the foam and the rear insert. A peripheral edge 182 of the shell remains exposed. The inserts each include a plurality of resilient tab members 184, 186, or catch members, that extend through openings 188 formed in the shell 170. The resilient tab members (catch members) 184, 186 are engaged with a snap fit to complete the assembly, sandwiching the shell 170 between the inserts.”) It would have been obvious to one of ordinary skill in the art to perform the method steps as recited in Claims 1, 3-4, 11, and 13-14 as this would be the normal and logical manner of changing a decorative feature for use with a chair as taught by the reference discussed above.
As for Claim 5, IACOVONI et al. teach that the panel 174 can be formed from a plastic resin since “backrest member 160” is made of a rigid plastic material.
As for Claim 6, IACOVONI et al. teach that a portion of the snap-fit 186 feature is integral with the panel 174.
As for claims 7 and 15, IACOVONI et al. teach that a first portion 186 of the snap-fit feature is integral with the panel and a second portion 188 of the snap-fit feature is integral with the back support; the snap-fit joint further includes a second portion integral with the back support, the first and second respective portions configured to engage with one another (see annotated Fig. 2 above).
As for claims 9-10 and 17, IACOVONI et al., teach that the first portion of the snap-fit joint includes a cantilever portion and an annular portion (see annotated Fig. 2 above); wherein the annular portion includes a feature configured to readily couple to and uncouple from the panel.
Claims 8, 16, and 20 are objected to as being dependent upon a rejected base claim but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims.
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure because it teaches structures and concepts similar to those of the present invention.
Response to Arguments
Claims 1 and 11 recite “wherein unsnapping the snap-fit joint includes the user readily separating the first panel from the back support”, which is the subject matter of original Claim 2. The specification does not appear to provide an explicit objective standard for what “readily separating” means. What is the meaning of “readily separating” Does it mean that removal is accomplished by a tool-free operation? Is removal done by hand? Does it mean to uncouple and recouple? There is no clear threshold for what is intended or defined by “readily separating”? Paragraph [0048] of IACOVONI et al. (U.S. Patent Application Publication No. 2011/0272986 A1) clearly states “To disassemble either or both of the backrest 4 and insert member (plug or arm) 61, 64, for example to replace a plug with an armrest or vice versa, the retainer member 312 is biased to a disengaged position, with the insert member and backrest then being removed and/or replaced with another or the same insert member and/or backrest member.” So, IACOVONI et al. teaches “unsnapping the snap-fit joint including the user readily separating the first panel from the back support”. IACOVONI et al. also teaches a “second panel” since it discloses the “backrest then being removed and/or replaced with another or the same insert member and/or backrest member” and therefore teaches “replacing the first panel with a second panel by snapping the second panel to the back support using the snap-fit joint” as claimed in Claim 1.
Claim 11 differs from and is broader than Claim 1, since Claim 1 simply claims a method of “removing” the panel. It is obvious to remove a panel, for example, if it needs to be replaced because it was damaged.
As for Claim 18, Conner et al. (U.S. Patent No. 6,042,187) does an interchangeable panel having a surface finish feature, the interchangeable panel configured for tool-less attachment to the chair, as defined in Claim 18. The fastening tabs are flexible and include a ridge 147 … which snaps onto a retaining bar 148 in attachment apertures 146 (also see column 8, lines 32-45 where it reads “Outer shell 34 is further secured to inner shell 32 via fastening tabs 116, 118, and 120. Depending upon what height outer shell 34 is being attached to inner shell 32 at, one set of fastening tabs 116, 118, and 120 are inserted into attachment apertures 146 and inner shell 32 (FIGS. 4, 5). If inner shell 32 is molded at its shortest height, fastening tabs 116a, b are inserted into attachment apertures 146 in inner shell 32. The fastening tabs are flexible and include a ridge 147 (FIG. 15) which snaps onto a retaining bar 148 in attachment apertures 146. The remaining fastening tabs 118 and 120 fit into compartments 150 and 152 defined by the grid-work formed by ribs 90 (FIG. 5). The fastening tabs in compartments 150 and 152 do not snap onto any portion of inner shell 32.”)
Conclusion
THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
As for Claim 18,
It does describe that the back shell 34 can snap in: The fastening tabs are flexible and include a ridge 147 … which snaps onto a retaining bar 148 in attachment apertures 146; see column 8, lines 32-45.
So, the back panel can attach tool-lessly to the chair. Applicant argues that the inner and outer shell are secured together by wings, etc. That may be true- the front shell looks like it needs tools; but the claim just reads “panel configured for tool-less attachment to the chair”. So even if the overall chair of Conner is not tool-lessly put together, the back panel can snap in and it would at least meet claim 18.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to Rodney B. White whose telephone number is (571)272-6863. The examiner can normally be reached 8:30 AM-5:00 PM.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, David R. Dunn can be reached on (571) 272-6670. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/Rodney B White/Primary Examiner, Art Unit 3636
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